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Groundwater Contamination Under Control

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  • DOCUMENTATION OF ENVIRONMENTAL INDICATOR DETERMINATIONRCRA Corrective Action

    Environmental Indicator (EI) RCRAInfo Code (CA750)Migration of Contaminated Groundwater Under Control

    Facility Name: Revlon, Inc., Main Production FacilityFacility Address: 55 Talmadge Road, Edison, New JerseyFacility EPA ID#: NJD002520542

    Definition of Environmental Indicators (for the RCRA Corrective Action)

    Environmental indicators (EIs) are measures being used by the Resource Conservation and Recovery Act(RCRA) Corrective Action program to go beyond programmatic activity measures (e.g., reports receivedand approved) to track changes in the quality of the environment. The two EIs developed to date indicatethe quality of the environment in relation to current human exposures to contamination and the migrationof contaminated groundwater. An EI for non-human (ecological) receptors is intended to be developed inthe future.

    Definition of Migration of Contaminated Groundwater Under Control EI

    A positive Migration of Contaminated Groundwater Under Control EI determination (YE statuscode) indicates that the migration of contaminated groundwater has stabilized, and that monitoring willbe conducted to confirm that contaminated groundwater remains within the original area ofcontaminated groundwater (for all groundwater contamination subject to RCRA corrective action at orfrom the identified facility (i.e., site-wide)).

    Relationship of EI to Final Remedies

    While final remedies remain the long-term objective of the RCRA Corrective Action program, the EIs arenear-term objectives which are currently being used as program measures for the GovernmentPerformance and Results Act of 1993 (GPRA). The Migration of Contaminated Groundwater UnderControl EI pertains ONLY to the physical migration (i.e., further spread) of contaminated groundwaterand contaminants within groundwater (e.g., non-aqueous phase liquids or NAPLs). Achieving this EIdoes not substitute for achieving other stabilization or final remedy requirements and expectationsassociated with sources of contamination and the need to restore, wherever practicable, contaminatedgroundwater to be suitable for its designated current and future uses.

    Duration / Applicability of EI Determinations

    EI determination status codes should remain in the Resource Conservation and Recovery Act Information (RCRAInfo) national database system ONLY as long as they remain true (i.e., RCRAInfo status codesmust be changed when the regulatory authorities become aware of contrary information).

  • Revlon, Inc., Main Production FacilityCA750Page 2

    Facility Information

    The Revlon, Inc., (Revlon) Main Production Facility is located on a 63.2-acre parcel in Edison Township,Middlesex County, New Jersey. Prior to 1948, the site was used for agricultural purposes. The propertywas purchased by Johnson & Johnson, Inc., in 1948 and was used as a distribution center for its baby careproducts until 1956. Revlon purchased the property and began operations in 1956. Revlons primarymanufacturing operations consisted of cosmetic formulations and packaging of lipstick, dusting powder,fragrances, toiletries, nail enamel, and makeup. Raw materials used in manufacturing included naturalmaterials, cosmetic formulations, and a variety of industrial chemicals. In 1985, Revlon entered into amerger agreement with Nicole Acquisition Company. The New Jersey Department of EnvironmentalProtection (NJDEP) viewed this merger as a change of ownership and subjected the property to aninvestigation under the provisions of the New Jersey (NJ) Environmental Cleanup and Responsibility Act(ECRA). In 1992, Revlon ceased operations at the facility. As a result of the ECRA inspection, 23 areasof concern (AOCs) were identified, most of which have been issued no further action (NFA)determinations. AOCs 5 and 6, both of which have subsurface soil contaminated with arsenic, are cappedwith asphalt and included in a deed notice. As a result of past facility operations, groundwater is alsocontaminated at concentrations above the NJ Ground Water Quality Criteria (GWQC). The groundwatercontamination is being remediated through operation of a groundwater extraction and treatment system. On July 25, 1999, a development company, Starwood Heller, LLC (Starwood Heller), purchased theproperty from Revlon. Currently, no manufacturing operations are conducted at this site. However, thefacility is currently leased by several tenants for warehousing and office space. Starwood Heller isconducting remediation activities at the site with oversight from NJDEP and EPA.

  • Revlon, Inc., Main Production FacilityCA750Page 3

    1. Has all available relevant/significant information on known and reasonably suspected releases tothe groundwater media, subject to RCRA Corrective Action (e.g., from Solid Waste ManagementUnits (SWMU), Regulated Units (RU), and Areas of Concern (AOC)), been considered in this EIdetermination?

    X If yes - check here and continue with #2 below.

    If no - re-evaluate existing data, or

    If data are not available, skip to #8 and enter IN (more information needed) statuscode.

    Summary of AOCs: The AOCs listed below have been identified at the facility and are considered forthis evaluation. A total of 23 AOCs were identified. Of these, all but two (AOCs 5 and 6) have receivedNFA determinations for soil. To facilitate investigation and remediation, areas of groundwatercontamination have been combined into the Groundwater AOC, as outlined in the discussion below. Refer to Attachment 3 of the approved CA725 for Revlon (Ref. 5) for a map of the AOC locations.

    AOC 1 Former Crusher, Dumpster, 4,000-Gallon Holding Tank, and Storm Drain Area: This AOC is located east of the hydrocarbon facility building. The holding tank, dumpster, andstorm drain received crusher discharges. Concentrations of beryllium, diethylphthalate, andthallium were detected in the soil at concentrations above the NJ Residential Direct Contact SoilCleanup Criteria (RDCSCC). However, upon the application of the NJDEP ComplianceAveraging procedure, these contaminants in the soil were determined not to be a concern in thisarea. The Compliance Averaging procedure allows for the average contaminant concentration inan AOC to be used to determine compliance with remediation standards or the soil cleanupcriteria, rather than the contaminant concentration of individual samples. The technical rules (atNew Jersey Administrative Code [NJAC] 7:26E-4.9(c)3i) specify certain requirements foraveraging data. NJDEP approved a NFA determination for soil on May 16, 1995. Shallowgroundwater in this area was previously monitored at well MW-21-45, but monitoring was laterdiscontinued due to a consistent lack of detection of groundwater constituents exceeding the NJGWQC. AOC 1 should not be confused with Groundwater AOC 1, which includes AOCs 11, 12,and 13.

    AOC 2 Stained Soil Adjacent to the East Side of the Main Manufacturing Building: Initialsoil samples collected at AOC 2 contained volatile organic compounds (VOCs); however, theresults of subsequent sampling events reported VOC concentrations below NJ RDCSCC. NJDEP approved a NFA determination for soil on May 16, 1995. AOC 2 was initially classifiedas a groundwater contamination source location. The primary contaminants of concern werevinyl chloride and trichloroethene, and more recent results (October 2003) also indicate 1,1-dichloroethene concentrations slightly above NJ GWQC. This AOC was determined not to be asource location, and well MW-22-45 was downgraded from a source monitoring well to acompliance monitoring well.

    AOC 3 RCRA Drum Storage Pad and Underground Storage Tanks (USTs) 15 and 16: Analysis of initial soil samples from this area revealed thallium at concentrations above NJRDCSCC. Revlon argued that the thallium contamination encountered in soil was naturally

  • Revlon, Inc., Main Production FacilityCA750Page 4

    occurring on a regional scale and not the result of site operations and activities. The NJDEPaccepted the facilitys position and approved a NFA determination for soil on May 16, 1995.

    AOC 4 East Stained Paved Area: This AOC is located east of the main manufacturingbuilding. Soil samples collected from this area were tested for metals and VOCs. The resultsshowed that the concentrations of VOCs and metals in the soil did not exceed NJ RDCSCC. NJDEP approved a NFA determination for soil on May 16, 1995.

    AOC 5 North Paved Area Adjacent to the Northwest Face of the Main Production Facility: This paved area extends from the centerline of the facility building to the north corner of thebuilding. Soil samples collected from both surface and subsurface soil in this area containedarsenic concentrations. The arsenic concentrations in the soil are attributable to the use ofhistorical fill material. Arsenic concentrations detected in surface soil were below the NJRDCSCC; however, arsenic contamination detected in subsurface soil exceeded the NJ RDCSCC. This area is capped with asphalt, which minimizes the infiltration of water through the arsenic-contaminated soil and prevents human exposure. The soil contamination in this area has beenaddressed by a deed notice.

    AOC 6 West Paved Area Adjacent to the Northwest Face of the Main Production Facility: This paved area extends from the centerline of the building to the west corner of the building. Soil samples collected from both surface and subsurface soil in this area contained arsenicconcentrations. The arsenic contamination in the soil is attributable to the use of historical fillmaterial. Arsenic contamination in surface soil was below the NJ RDCSCC; however,concentrations in subsurface soil exceeded the NJ RDCSCC. This area is capped with asphalt,which minimi